Are We Solving the Right ACH Problems?
The payments industry loves to talk about innovation.
Yet at the same time, many financial institutions are still struggling with some of the most fundamental operational challenges within their payments programs.
That’s one reason Nacha’s recent Requests for Comment (RFCs) and Requests for Information (RFIs) are so interesting.
On the surface, the topics may not seem particularly exciting—return timeframes, dishonored returns, banking day definitions.
But these proposals say a lot about where the ACH Network is headed—and where financial institutions should be focusing their attention.
Because while much of the industry is focused on making payments move faster, Nacha appears to be asking a different question:
Can we resolve issues faster when something goes wrong?
The Reality Behind ACH Operations
Most institutions have spent years discussing payment innovation.
Meanwhile, many are still:
- Manually tracking ACH returns
- Struggling to establish meaningful monitoring programs
- Relying on procedures that haven’t been updated in years
Community financial institutions, in particular, are being asked to do more than ever before—often with limited resources, increasing compliance expectations, and rapidly evolving payment options.
That’s exactly why these proposals matter.
They highlight a shift: operational efficiency and risk management are becoming just as important as payment speed.
Faster Returns Mean Faster Decisions
One proposal would shorten return timeframes for certain administrative returns.
At first glance, that may sound like a minor operational change. In reality, it raises much larger questions:
- How quickly can your institution identify an issue?
- How quickly can your staff investigate it?
- How quickly can a decision be made?
- Are your current processes built to support shorter timeframes?
Many institutions spend significant time discussing fraud monitoring, onboarding, and exposure limits. Those are all important.
But the ability to identify, escalate, and resolve exceptions efficiently is becoming equally critical.
As the network moves faster, there’s less room for operational inefficiencies.
Clarity Matters More Than Most People Realize
Nacha is also seeking feedback on the definition of a Banking Day and other operational topics.
Definitions matter—because definitions drive expectations.
They influence:
- Processing timelines
- Return deadlines
- Operational responsibilities
- Compliance obligations
When rules leave room for interpretation, institutions often develop their own practices. Over time, those practices become deeply embedded—even when they no longer align with industry expectations.
This is something that frequently surfaces during ACH audits and risk assessments.
Staff are doing what they’ve always done—but what they’ve always done may not be what the Rules intended.
Dishonored Returns Are a Good Reminder
The Request for Information around dishonored returns, contested dishonored returns, and corrected dishonored returns is another example.
Most institutions don’t deal with these situations often.And that’s exactly the problem.
The greatest operational risks are often tied to activities that occur infrequently.
When issues only arise a few times a year:
- Staff may not remember the requirements
- Procedures may lack sufficient detail
- Escalation paths may be unclear
The result is often confusion, delays, and unnecessary risk.
What Institutions Should Do Now
Whether these proposals are adopted as written or modified through the comment process, they create an opportunity for self-evaluation.
Financial institutions should be asking:
- Do our procedures reflect how we actually operate today?
- Would we be able to meet shorter return deadlines?
- Are staff trained on uncommon return and exception scenarios?
- Do our monitoring processes identify issues quickly enough?
- Have we objectively evaluated our ACH program within the last year?
Too often, organizations wait until a rule change becomes effective before assessing their readiness.
By that point, the response becomes reactive.
The most successful institutions take a different approach—they evaluate their programs before they are required to.
Final Thought
The future of payments isn’t just about moving money faster.
It’s about ensuring your people, processes, and controls can keep up as the network evolves.
Need a Closer Look?
If these questions are prompting a closer look at your ACH operations, NPG can help you assess your current processes and identify opportunities to strengthen efficiency and reduce risk.